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The gift certificates provided to union members will probably be considered a reimbursement of union dues. ...

At the time the damages are so ascertained (and not before), the taxpayer incurs an absolute and unconditional obligation to pay an amount and an expense is considered to be incurred for income tax purposes. ...

You request our assistance in determining whether an amount paid by an employer as a grievance settlement is considered a qualifying retroactive lump-sum payment ("QRLSP") for purposes of section 110.2 of the Income Tax Act (the "Act") and as described in Form T1198E. ...

The determination of what is considered a "reasonable reserve" can only be made after considering all of the facts and circumstances surrounding a particular situation. ...

Where a personal expense such as elder or child care is paid by an employer, the employee will normally be considered to have received a taxable employment benefit. ...

Component parts of buildings such as electric wiring, plumbing, sprinkler systems, air-conditioning equipment and heating equipment are considered to be capital expenditures under the Act. ...

Generally, premiums paid under a life insurance policy are considered to be on account of capital, and are therefore not deductible pursuant to paragraph 18(1)(b) of the Income Tax Act (the "Act"). ...

These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R5 dated May 17, 2002, issued by the Canada Revenue Agency (the CRA) and are not considered binding on the CRA. ...

It should also be noted that even if the function test was considered to be met during the leave period, in our view, the income received from an income maintenance insurance plan is not remuneration from a qualifying office or employment and would not be included in the above calculations. ...

In the above example, it is our view that while the taxation year of Corporation A may be deemed to have ended pursuant to subsection 249(3.1) as a result of the corporation ceasing to be a CCPC, the shares of Corporation A would not be precluded from being considered QSBC shares under subsection 110.6(1) at the time they are disposed of by the shareholders of Corporation A solely because Corporation B acquired rights to acquire the shares of Corporation A under the purchase and sale agreement. ...